Information — United States v. Oluwatobi Sensi Seton, Southern District of Indiana (Document 37)
Summary
Information filed August 2, 2022 as Document 37 in United States of America v. Oluwatobi Sensi Seton, Case 1:22-cr-00099-TWP-MJD, U.S. District Court, Southern District of Indiana, Indianapolis Division. Count One charges conspiracy to commit wire fraud under 18 U.S.C. § 1349, alleging that from in or about February 2020 to in or about January 2021 the defendant and others used stolen personal information to apply for unemployment and other benefits and to open GoBank prepaid debit cards, and that the conspiracy caused over $4 million in actual losses and over $1 million in attempted losses. Count Two charges aggravated identity theft under 18 U.S.C. § 1028A(a)(1) and (c)(5), and Count Three charges conspiracy to commit money laundering under 18 U.S.C. § 1956(h). The information includes forfeiture allegations listing seized items and sums.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
Cite this document
“Information — United States v. Oluwatobi Sensi Seton, Southern District of Indiana (Document 37).”
Original at ecf.insd.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-usa-v-seton-dkt-37-e25860dc69/
, SHA-256 6d2f631db3b8a47311c07dce4eb76e0aebe7f0889e4099f91b5c35171c931dc5.Full text
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 1 of 10FILED
PageID #:
140
3:20 pm, Aug 02, 2022
U.S. DISTRICT COURT
UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA
SOUTHERN DISTRICT OF INDIANA Roger A.G. Sharpe, Clerk
INDIANAPOLIS DIVISION
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
V. ) CAUSE NO. 1:22-cr-00099-TWP-DLP
)
OLUWATOBI SENSI SETON, )
)
Defendant. )
INFORMATION
The United States Attorney charges that:
General Allegations
At times material to this Information:
1. OLUWATOBI SENSI SETON (“SETON”) was a citizen of Nigeria who resided
in Bloomington, Indiana.
2. The “Benefit Victims” were hundreds of individuals residing in locations
throughout the United States, whose personally identifiable information was used by SETON and
her conspirators to apply for unemployment and other state and federal benefits without the
knowledge and authorization of these individuals.
3. The “GoBank Victims” were hundreds of individuals residing in locations
throughout the United States, whose personally identifiable information was used by SETON and
her conspirators to open and register prepaid debit cards and related accounts at GoBank, a
financial institution, which were used to receive the unemployment and other state and federal
1
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 2 of 10 PageID #:
141
benefits applied for in the names of the Benefit Victims, all without the GoBank Victims’
knowledge and authorization.
4. The term, personally identifiable information (“PII”), as used herein, refers to any
information related to identifying a person, including but not limited to their name, date of birth,
and social security number.
Count One
Conspiracy to Commit Wire Fraud
(Title 18, United States Code, Section 1349)
5. Paragraphs 1 through 4 are re-alleged and incorporated herein by reference.
6. Beginning in or about February 2020, and continuing to in or about January 2021,
within the Southern District of Indiana and elsewhere,
OLUWATOBI SENSI SETON
the Defendant herein, did knowingly and willfully combine, conspire, confederate and agree with
others known and unknown, to violate Title 18, United States Code, Section 1343 (“Wire
Fraud”), that is, to knowingly and with intent to defraud, devise and intend to devise, and
willfully participate in, with knowledge of its fraudulent nature, the scheme and artifice to
defraud and to obtain money and property by means of false and fraudulent pretenses,
representations, or promises described below (the “Scheme”), and for the purpose of executing
such scheme and artifice, or attempting so to do, knowingly transmitted and caused to be
transmitted by means of wire, radio, or television.
2
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 3 of 10 PageID #:
142
Purpose of the Conspiracy and the Scheme to Defraud
7. It was the purpose of the conspiracy and Scheme to obtain unemployment and
other benefits from state and federal governments by falsely applying for such benefits using the
stolen identities of the Benefits Victims.
8. It was further the purpose of the conspiracy and Scheme to conceal the source of
the stolen funds and distribute them to conspirators within the United States and abroad.
Manner and Means
The following were the manners and means of the conspiracy and Scheme:
9. Conspirators in Nigeria provided SETON with PII of GoBank Victims. SETON
and other conspirators used that PII to purchase, open, and register GoBank prepaid debit cards
and associated GoBank bank accounts. The purpose of these accounts was to receive stolen
unemployment and other government benefits.
10. Conspirators submitted false and fraudulent unemployment applications and other
state and federal benefit applications to unemployment agencies throughout the United States in
the names of Benefit Victims, including in Indiana. The conspirators used PII of Benefit
Victims to apply for unemployment benefits without the Benefit Victims knowledge or
authorization. The applications directed that the benefits be deposited on the GoBank prepaid
debit cards that SETON and other conspirators opened.
11. For instance, on or about June 16, 2020, SETON purchased a GoBank card and,
on or about June 18, 2020 activated and registered the card in the name of S.W. (a GoBank
Victim and Benefits Victim) using, among other things, S.W.’s name, date of birth, and social
security number. Between June 22, 2020 and December 29, 2020, approximately $16,722 of
3
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 4 of 10 PageID #:
143
funds were deposited into the S.W. GoBank account from multiple state employment agencies,
including $8,388 in unemployment benefits from the Indiana Department of Workforce
Development based on an application in the name of S.W. containing, among other things,
S.W.’s name, date of birth, and social security number. The real S.W. did not apply for
unemployment nor was S.W. aware of or authorized the filing of such application. The real
S.W. also did not register the GoBank card, nor was S.W. aware of or authorized such
registration.
12. Once the government benefits were transferred to the GoBank accounts, SETON
used the GoBank prepaid debit cards to withdraw the funds in the form of U.S. Currency, bring
the currency to Walmart locations throughout Indiana and Illinois, and convert the cash to money
orders. SETON used fictitious driver’s licenses to show proof of identification for the withdrawal
of the money. ATM withdrawals using GoBank prepaid debit cards in Indiana caused wire
transmissions in interstate or foreign commerce.
13. SETON then, at the direction of her co-conspirators in Nigeria, provided the
money orders to other individuals whose role in the scheme was to send or transfer the stolen
funds back to the conspirators, including those in Nigeria. SETON conversed and coordinated
with these other individuals, meeting them at various locations in Indiana and Illinois to deliver
the money orders.
14. SETON retained a portion of the proceeds for her participation in the scheme.
15. The conspiracy caused over $4 million USD in actual losses and over $1 million
in attempted losses to state and federal agencies.
All of which is a violation of Title 18, United States Code, Section 1349.
4
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 5 of 10 PageID #:
144
Count Two
Aggravated Identity Theft
(Title 18, United States Code, Section 1028A(a)(1) and (c)(5))
16. Paragraphs 1 through 15 are re-alleged and incorporated herein by reference.
17. On or about June 18, 2020, within the Southern District of Indiana and elsewhere,
OLUWATOBI SENSI SETON,
the Defendant herein, during and in relation to the foregoing felony violation of Title 18, United
States Code, Section 1343 (wire fraud) as alleged in Count 1 above, knowingly possessed and
used, without lawful authority, a means of identification of another person, in and affecting
interstate commerce, that is, the Defendant possessed the name, date of birth, and social security
number of S.W., and utilized that PII to register a GoBank prepaid debit card and associated
GoBank account in the name of S.W. to receive the proceeds of the scheme.
All of which is a violation of Title 18, United States Code, Sections 1028A(a)(1) and
(c)(5).
5
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 6 of 10 PageID #:
145
Count Three
Conspiracy to Commit Money Laundering
(Title 18, United States Code, Sections 1956(h) and 1956(a)(1)(B)(i))
18. Paragraphs 1 through 17 are re-alleged and incorporated herein by reference.
19. Beginning in or about February 2020, and continuing to in or about January 2021,
within the Southern District of Indiana and elsewhere,
OLUWATOBI SENSI SETON,
the Defendant herein, did knowingly and willfully combine, conspire, and agree with other persons
known and unknown to commit offenses against the United States, to wit: to knowingly conduct
and attempt to conduct financial transactions affecting interstate commerce and foreign commerce,
which transactions involved the proceeds of specified unlawful activity, that is, the Scheme
described herein, knowing that the transactions were designed in whole or in part to conceal and
disguise the nature, location, source, ownership, and control of the proceeds of specified unlawful
activity, and that while conducting and attempting to conduct such financial transactions, knew
that the property involved in the financial transactions represented the proceeds of some form of
unlawful activity.
All of which is a violation of Title 18, United States Code, Sections 1956(h) and
1956(a)(1)(B)(i).
6
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 7 of 10 PageID #:
146
FORFEITURE
20. The allegations contained in Counts 1 through 3 of this Information are re-alleged
and incorporated by reference for the purpose of alleging forfeitures pursuant to Title 18, United
States Code, Sections 981(a)(1)(A), 981(a)(1)(C) and 982(a)(1), and Title 28, United States Code,
Section 2461(c).
21. Pursuant to Title 18, United States Code, Sections 981(a)(1)(A), 981(a)(1)(C) and
982(a)(1), and Title 28, United States Code, Section 2461(c), upon conviction of a violation of the
offenses in Title 18, United States Code, Section 1349 and 1343 set forth in Count 1 of this
Information, and in Title 18, United States Code, Section 1956(h) set forth in Count 3 of this
Information,
OLUWATOBI SENSI SETON
the Defendant herein, shall forfeit to the United States of America:
a. any property, real or personal, involved in a transaction or attempted
transaction in violation of Title 18, United States Code, Section 1956, or any property
traceable to such property; or
b. any property, real or personal, which constitutes or is derived from proceeds
traceable to a violation of Title 18, United States Code, Section 1343, or a conspiracy to
commit such offense; or
c. a sum of money equal to the total amount of the proceeds of the offenses.
22. The property subject to forfeiture includes, but is not necessarily limited to the
following:
7
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 8 of 10 PageID #:
147
Item
Description Location Seized
No.
$2,091.00 USD Seized by the Monroe County
1 Sheriff’s Department on January 12,
2021
Seized by the Monroe County
1,321 prepaid Cards
2 Sheriff’s Department on January 12,
2021
Seized by the Monroe County
3 Fifty-two (52) sealed Visa prepaid cards Sheriff’s Department on January 12,
2021
Seized by the Monroe County
One (1) sealed American Express card and
4 Sheriff’s Department on January 12,
one (1) American Express card
2021
Seized by the Monroe County
Black and Red Acer laptop computer S/N
5 Sheriff’s Department on January 12,
NHQSWAA001927032B33400
2021
Seized by the Monroe County
6 Thirty-two (32) Visa prepaid cards Sheriff’s Department on January 12,
2021
Seized by the Monroe County
7 Black USB Drive Sheriff’s Department on January 12,
2021
Seized by the Monroe County
Four (4) Alcatel cell phones with batteries and
8 Sheriff’s Department on January 12,
charger
2021
Seized by the Monroe County
9 White HP laptop computer S/N 5CD74614D Sheriff’s Department on January 12,
2021
Seized by the Monroe County
Twelve (12) sealed GreenDot Visa cards and
10 Sheriff’s Department on January 12,
One (1) sealed MyVanilla card
2021
Three (3) New York identification cards, Five Seized by the Monroe County
11 (5) Texas identification cards, and Two (2) Sheriff’s Department on January 12,
California identification cards. 2021
Seized by the Monroe County
One (1) black iPhone & 1 Silver iPhone, FCC
12 Sheriff’s Department on January 12,
ID BCG-E2945A
2021
800 E. North Street, Storage Unit
13 $63,260 Cash
2041, Crown Point, Indiana
7937 West 19th Street, Unit D47,
14 Silver Meizu Phone; Pro5 TD-LTE Indianapolis, Indiana
8
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 9 of 10 PageID #:
148
Item
Description Location Seized
No.
Black LG Cell Phone; Model LM-X420MM; 7937 West 19th Street, Unit D47,
15 Indianapolis, Indiana
IMEI: 359962-10-383255-4
7937 West 19th Street, Unit D47,
16 Black Coolpad Phone Indianapolis, Indiana
Grey iPhone S, Model A1688, FCC ID: BCG- 7937 West 19th Street, Unit D47,
17 Indianapolis, Indiana
E2946A, IC: 579C-E2946A
7937 West 19th Street, Unit D47,
18 $19,800 Cash
Indianapolis, Indiana
1330 Morton Avenue, Unit A3,
19 $1,500 Cash
Martinsville, Indiana
GoBank Accounts – Seizure Warrant
20 $210,840.08
(21-mj-0073)
GoBank Accounts – Seizure Warrant
21 $261,093.39
(21-mj-0745)
23. If any of the property described above, as a result of any act or omission of the
Defendant:
a. cannot be located upon the exercise of due diligence;
b. has been transferred or sold to, or deposited with, a third party;
c. has been placed beyond the jurisdiction of the court;
d. has been substantially diminished in value; or
e. has been commingled with other property which cannot be divided without
difficulty,
the United States of America shall be entitled to forfeiture of substitute property pursuant to Title
21, United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section
2461(c).
9
Case 1:22-cr-00099-TWP-MJD Document 37 Filed 08/02/22 Page 10 of 10 PageID #:
149
File and source
- File
- 37-information-felony-as-to-oluwatobi-sensi-seton.pdf
- Size
- 450,966 bytes
- SHA-256
- 6d2f631db3b8a47311c07dce4eb76e0aebe7f0889e4099f91b5c35171c931dc5
- Original
- PACER (login required)